‘Bound by Affection, Influence, or Obligation’: Decoding the Close-and-Continuing Test

Posted by Ashley Jones

The phrase “bonds of affection” does not appear in the SF-86’s foreign contacts question. It sits on page 40, in the marital-status block, attached to a different test. Section 19, on page 60, asks about people with whom you are “bound by affection, influence, common interests, and/or obligation.” Section 17.3 asks whether you live with someone with whom you “share bonds of affection, obligation, or other commitment.” Two clauses, two sections, two separate legal questions.

Key takeaways

  • Across all 129 numbered pages of the November 2016 revision, the form never defines “close and/or continuing contact” or “bound by affection.” The only term Section 19 defines is “foreign national.”
  • Section 19 looks back seven (7) years and gives the paper form four entry slots. “Bonds of affection” belongs to Section 17.3, the cohabitant question, on page 40.
  • SEAD 3, effective 12 June 2017, puts foreign-contact reporting in Section F, “Reportable Activities for All Covered Individuals,” binding every clearance level rather than Top Secret alone.
  • SEAD 4, effective 8 June 2017, makes failure to report an independent disqualifier at ¶ 7(c) and prompt reporting an express mitigator at ¶ 8(e). Over-disclosure carries no matching penalty.
  • Section 18 enumerates 16 relative types. Grandparents, aunts, uncles, cousins, nieces and nephews are not among them, so a foreign-national grandmother is judged under Section 19.
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What exactly does SF-86 Section 19 ask?

One sentence, on page 60 of the November 2016 Standard Form 86. It reaches close and/or continuing contact with a foreign national inside a seven-year window, and it does not stop at your own contacts.

“Do you have, or have you had, close and/or continuing contact with a foreign national within the last seven (7) years with whom you, or your spouse, or legally recognized civil union/domestic partner, or cohabitant are bound by affection, influence, common interests, and/or obligation? Include associates as well as relatives, not previously listed in Section 18.”

Read the scope clause again. The printed form names four categories: you, your spouse, your legally recognized civil union or domestic partner, and your cohabitant. The third is easy to skim past and it is not decorative. A domestic partner’s foreign contacts are your disclosure obligation.

The form defines exactly one term in that sentence: “A foreign national is defined as any person who is not a citizen or national of the U.S.” Nothing about visa category, so a lawful permanent resident holding a green card is a foreign national here.

Where does “bonds of affection” actually come from?

Section 17.3, the cohabitant question, on page 40. Not the foreign contacts question at all. It asks about the person you live with, and it expressly excludes a roommate.

The question reads: “Do you presently reside with a person, other than a spouse or legally recognized civil union/domestic partner, with whom you share bonds of affection, obligation, or other commitment, as opposed to a person with whom you live for reasons of convenience (e.g. a roommate)?”

Set that beside Security Executive Agent Directive 3, which at § D.3 defines “Cohabitant” as “a person with whom the covered individual resides and shares bonds of affection, obligation, or other commitment, as opposed to a person with whom the covered individual resides for reasons of convenience (e.g. a roommate).” The form question is the directive’s definition restated as a question. Same phrase, same carve-out, same parenthetical.

That controls how you answer. The dividing line is not a shared lease. It is whether the arrangement runs on convenience or on commitment. A stranger you found online to split rent is a roommate. A long-term partner you never married is a cohabitant, and their foreign contacts flow into your Section 19 answer.

If the form never defines “close and/or continuing,” what does?

Nothing on the form. A search of the full form text returns the phrase five times, all inside the Section 19 question and its four entry prompts. The nearest authority sits outside the form, in SEAD 4’s mitigating conditions and SEAD 3’s reporting rule, and both work by naming what the standard excludes.

Start with the conjunction. “Close and/or continuing” is disjunctive. Either limb suffices. A single intense relationship that has ended qualifies on closeness alone; a thin but persistent tie qualifies on continuity alone. Read as a two-part test, it narrows further than its words allow.

SEAD 4, the National Security Adjudicative Guidelines, gives the mirror image at Guideline B ¶ 8(c), which mitigates when “contact or communication with foreign citizens is so casual and infrequent that there is little likelihood that it could create a risk for foreign influence or exploitation.” SEAD 3 § F.2.b.2 draws the line from the other side: “The reporting of limited or casual public contact with foreign nationals is not required absent any other reporting requirement in this directive.” Casual plus infrequent falls outside. Substance on either axis falls inside. Neither authority supplies a contact count, because the concern is not volume.

The text also forecloses one argument in advance. SEAD 4 ¶ 7(a) makes disqualifying “contact, regardless of method,” with a foreign associate, friend or family member where it creates a heightened risk of exploitation, inducement, manipulation, pressure or coercion. SEAD 3 § F.2.b.2 applies “regardless of how or where the foreign national contact was made or how the relationship is maintained.”

Which clause is defined where?

Six clauses. Exactly one carries a definition printed on the form.

Clause Defined where What it does not reach
“close and/or continuing” Nowhere on the form. Nearest: SEAD 4 ¶ 8(c), SEAD 3 § F.2.b.2 “limited or casual public contact”
“a foreign national” The form, Section 19 Visa class. Green-card holders stay inside it
“within the last seven (7) years” The form. A look-back for the application only Your duty afterward, left open-ended by SEAD 3 § E.1
“spouse, civil union/domestic partner, or cohabitant” “Cohabitant” at SEAD 3 § D.3, mirrored in Section 17.3 Anyone you live with “for reasons of convenience”
“bound by affection, influence, common interests, and/or obligation” Undefined. Closest gloss is the form’s own checkbox for “Personal” ties No emotional tie required. “Common interests” alone satisfies it
“associates as well as relatives, not previously listed in Section 18” Section 18’s closed list of 16 relative types Only relatives Section 18 already captured

Which relatives fall to Section 19 instead of Section 18?

More than applicants expect. Section 18 lists 16 relative types and tells you to select each one “applicable to you, regardless if they are living or deceased.” The list is closed, so every blood relation outside it is judged under the close-and-continuing test.

The 16 are mother, father, stepmother, stepfather, foster parent, child (including adopted and foster), stepchild, brother, sister, stepbrother, stepsister, half-brother, half-sister, father-in-law, mother-in-law, and guardian. Notice who is missing. Grandparents. Aunts and uncles. Cousins. Nieces and nephews. A foreign-national grandmother in Manila is not an automatic listing. She is a Section 19 judgment. Your spouse sits in Section 17, not 18, much as the bar on listing a relative as a reference or verifier catches people elsewhere on the form.

What does answering YES actually cost you?

More keystrokes than the question implies. Each contact requires name and nicknames, first and last contact by month and year, methods, frequency, nature of the relationship, citizenships, birth date and place, address, employer, and any affiliation with a foreign government, military, security service, defense industry or intelligence service.

The “nature of relationship” checkbox rewards close reading, because it is the nearest thing to a definition printed anywhere on the form. Of its four boxes the form glosses only one: “Personal (Such as family ties, friendship, affection, common interests, etc)”. That gloss shows the drafters treating common interests as a standalone basis. A hobbyist you have traded messages with for years about a shared technical field, with no personal warmth involved, sits inside the question.

Does the seven-year window ever close?

No. The seven years bound the application, not the obligation. Once you hold eligibility, SEAD 3 replaces the look-back with a standing forward duty to report foreign contacts that has no window at all.

SEAD 3 § E.1 states that “all covered individuals incur a special and continuing security obligation to be aware of the risks associated with foreign intelligence operations and/or possible terrorist activities directed against them in the United States and abroad.” The rule at § F.2.b.2 then reaches “continuing association with known foreign nationals that involve bonds of affection, personal obligation, or intimate contact; or any contact with a foreign national that involves the exchange of personal information.”

Its placement carries two lessons. It sits under Section F, headed “Reportable Activities for All Covered Individuals,” so it binds a Confidential holder as surely as a TS/SCI holder. And it does not demand endless updating: reports recur “only if and when there is a significant change in the nature of the contact.” Higher tiers add more. Section H, covering Top Secret and “Q” access and critical or special sensitive positions, separately requires reporting cohabitants, marriage, and “any foreign national(s) who co-occupies a residence for a period of more than 30 calendar days.” That threshold is not universal. Do not apply it to a Secret holder.

  SF-86 Section 19 SEAD 3 § F.2.b.2
Direction Look-back, at application Look-forward, for as long as you hold eligibility
Window Seven (7) years, four entry slots None stated
Triggers an update Filing or refiling the questionnaire “a significant change in the nature of the contact”
Cost of silence 18 U.S.C. 1001: a felony “revocation of national security eligibility”

Contractor employees carry a third layer. 32 CFR § 117.8, the NISPOM rule, incorporates SEAD 3 by reference and requires cleared employees to report events affecting eligibility. It also constrains your employer, which must report adverse information but “will not make reports based on rumor or innuendo.” Your FSO routes all of it, inside the wider structure of what Part 117 requires of a cleared employer.

What happens if you leave someone off?

The omission becomes its own problem, separate from whatever the relationship itself would have raised. SEAD 4 Guideline B ¶ 7(c) lists as disqualifying the “failure to report or fully disclose, when required, association with a foreign person, group, government, or country.” That condition stands alone.

Read it against ¶ 8(e), which mitigates where “the individual has promptly complied with existing agency requirements regarding the reporting of contacts, requests, or threats from persons, groups, or organizations from a foreign country.” The same act appears twice. Its absence disqualifies; its presence mitigates. Nowhere does the guideline penalize reporting a contact that proves immaterial. That asymmetry is the only decision rule most applicants need for a borderline name.

The authorities refuse, three separate times, to let nationality be the trigger. SEAD 4 ¶ 7(e) reaches “shared living quarters with a person or persons, regardless of citizenship status.” Paragraph 7(a) says “regardless of method.” And 32 CFR § 117.8(c)(2)(ii) makes a contractor report elicitation “by any individual, regardless of nationality.” What is under examination is the exposure a relationship creates, not the passport attached to it. Guideline B ¶ 6 gives the reason: foreign contacts concern adjudicators “if they result in divided allegiance” or leave someone open to being “manipulated or induced to help a foreign person, group, organization, or government in a way inconsistent with U.S. interests.” Disclosed contacts are then weighed through the whole-person concept rather than tallied.

The downside is concrete. The form warns that “knowingly falsifying or concealing a material fact is a felony which may result in fines and/or up to five (5) years imprisonment,” and the certification you sign acknowledges exposure to “denial or revocation of a security clearance.” An unreported contact surfaced later becomes a paragraph in a Statement of Reasons, and continuous vetting means it can surface at any point in the life of your eligibility.

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Frequently Asked Questions

Is a green-card holder a foreign national on the SF-86?

Yes. Section 19 defines a foreign national as “any person who is not a citizen or national of the U.S.” Lawful permanent residence is not citizenship, so a green-card holder falls inside it, and the form attaches no visa carve-out.

Does my cousin abroad go in Section 18 or Section 19?

Section 19, if the contact meets the close-and-continuing test. Section 18’s list of 16 relative types does not include cousins, grandparents, aunts, uncles, nieces or nephews. Those relations fall through to Section 19 and are judged on the nature of the contact.

Do I have to report my roommate?

Not on Section 17.3, which excludes a person you live with “for reasons of convenience (e.g. a roommate).” Separately, SEAD 3 § H.2.e requires Top Secret, “Q,” and critical or special sensitive holders to report any foreign national co-occupying a residence for more than 30 calendar days.

Does contact that happens only online count?

Yes. SEAD 3 § F.2.b.2 applies “regardless of how or where the foreign national contact was made or how the relationship is maintained (i.e. via personal contact, telephonic, postal system, Internet, etc.),” and SEAD 4 ¶ 7(a) reaches contact “regardless of method.” A years-long relationship conducted entirely through messages sits inside both.

Before you answer the question

What this article cannot do is tell you whether your particular relationship is reportable. That judgment belongs to your FSO or a clearance attorney who can see the facts. What the primary sources settle is the shape of the question, and the shape is wider than most applicants assume: a partner’s contacts count, an online-only relationship counts, common interests alone count. Notice, too, what the drafters chose to quantify. SEAD 3 gave money hard numbers at the Top Secret tier: debt more than 120 days delinquent, any “unusual infusion of assets of $10,000 or greater.” A reader weighing how much debt is too much has thresholds. For a foreign contact there are none, and the absence is the point.

So pull the actual pages. Read Section 17.3 on page 40 beside Section 19 on page 60, then read SEAD 3 § D.3 next to both, and the two clauses that look interchangeable at a glance separate cleanly. Then ask your partner the same question about their own contacts, because the form makes their answer part of yours. Applicants who do that in 2026 will file a form that still holds up under continuous vetting five years from now.

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  • Ashley Jones is ClearedJobs.Net's blog Editor and a cleared job search expert, dedicated to helping security-cleared job seekers and employers navigate job search and recruitment challenges. With in-depth experience assisting cleared job seekers and transitioning military personnel at in-person and virtual Cleared Job Fairs and military base hiring events, Ashley has a deep understanding of the unique needs of the cleared community. She is also the Editor of ClearedJobs.Net's job search podcast, Security Cleared Jobs: Who's Hiring & How.

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Author

  • Ashley Jones is ClearedJobs.Net's blog Editor and a cleared job search expert, dedicated to helping security-cleared job seekers and employers navigate job search and recruitment challenges. With in-depth experience assisting cleared job seekers and transitioning military personnel at in-person and virtual Cleared Job Fairs and military base hiring events, Ashley has a deep understanding of the unique needs of the cleared community. She is also the Editor of ClearedJobs.Net's job search podcast, Security Cleared Jobs: Who's Hiring & How.

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This entry was posted on Sunday, July 19, 2026 7:40 am